International Harvester Credit Corp. v. Goodrich, 350 U.S. 537 (1956)

International Harvester Credit Corp. v. Goodrich

No. 82

Argued January 17-18, 1956
Decided April 9, 1956
350 U.S. 537

APPEAL FROM THE COURT OF APPEALS OF NEW YORK

Syllabus

New York State imposes a highway use tax, computed by the weight-distance principle, upon motor carriers operating heavy vehicles on the State’s highways. The tax owed by a carrier is a statutory lien upon all motor vehicles operated by the carrier within the State, and the lien is paramount to all prior liens or encumbrances. Vendors of particular trucks, who sold them to the carrier under conditional sales agreements more than a year after the statute became effective, challenged application of the statutory tax lien, in some circumstances, as a deprivation of property without due process of law in violation of the Fourteenth Amendment to the Federal Constitution.

Held:

1. As applied to taxes based upon the carrier’s operation of other trucks within the State, whether before or during the time that the carrier operated the particular trucks within the State, the State’s priority of lien is constitutional. Pp. 538-548.

2. As applied to taxes assessed against the carrier after the vendors have repossessed the particular trucks, but which were based upon the carrier’s operations on the State’s highways before such repossession, the State’s priority of lien is constitutional. Pp. 538-548.

308 N.Y. 731, 124 N.E.2d 339, affirmed.